US v. Covington: Covington, a Bureau of Prisons official, and Farley, a BoP nurse, were both involved with an inmate, WW, who experienced a “medical crisis” (mental and physical) that lasted for more than a day and resulted in his death. Covington failed to seek medical attention for WW and Farley, after examining him, failed to call a doctor or have him taken to a hospital. Both were charged with depriving WW of his Eighth Amendment rights in a manner causing bodily injury or death and making false statements during the investigation of WW’s death. Covington was convicted on the civil rights charges (for causing injury, but not death), while Farley was acquitted, and both were convicted of making false statements. At sentencing, Farley’s Guideline range was enhanced based on events that occurred on the night WW died, which was two years before the false statement for which she was convicted.
On appeal, the Fourth Circuit vacated Covington’s civil rights conviction and Farley’s sentence. As to Covington, the primary issue was whether the Government was required to prove that Covington’s neglect was only a “but for” cause of WW’s injuries or that it was the “proximate cause” of such injuries. The court first concluded that the statute under which Covington was charged required a proximate cause standard, relying largely on law interpreting the statute covering conspiracies to deprive a person of their civil rights. That determined, the court held that the evidence was sufficient to sustain Covington’s conviction, but that the error in not instructing the jury on the proximate cause standard required a vacation of the conviction, noting the different standards of evaluating evidence in those two analyses. As to Farley, the court concluded that the district court erred in determining that the events of the night of WW’s death were relevant conduct for Farley’s offense of conviction. As such, it was required to vacate her sentence and remand.
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